SystemData Privacy & AI Governance

Data Mapping and ROPA

Data mapping software that tests your record of processing against what your systems really do, every week

Your record of processing matches what systems really do, checked every week, signed.

See one case, screen by screen ↓
demo214systemsread every night by the discovery agent at the demo company, from single sign-on to tag manager
demo1.6daysmedian from a change in a system to a drift item with its evidence, instead of the next annual review
demo88%of 412 activities in sync with their systems, up from 71% at go-live 14 weeks earlier
target0transferswithout a mechanism left unseen: every contract, tag and vendor notice re-checked on arrival
In short

What is Data Mapping and ROPA?

Data Mapping and ROPA is data mapping software for privacy teams that builds the record of processing activities from real systems and contracts and keeps it true. Eight agents read your systems, tags and contracts, test every activity's record against them every week, and draft cited corrections; process owners confirm, and the DPO approves and signs the Article 30 record.

How to choose AI solutions for back-office and enterprise work →

Updated

The problem

Why the record of processing is wrong a week after it is signed

Article 30 requires a controller to keep a written record of its processing activities — purposes, data subjects, data categories, recipients, third-country transfers, erasure time limits and security measures — available to the supervisory authority on request. In most enterprises that record is a spreadsheet built once a year from interviews and a long survey per activity. At the demo company, Kestrel & Vane Group, the March 2026 review took 11 weeks, 61 owners and a 58-question survey per activity.

Then the systems move on and the record does not. A release adds a date-of-birth field to a signup form; an agency publishes a pixel that sends hashed emails to a US vendor; marketing signs an order form whose data processing terms are "in Schedule 3", which is not attached. No survey asks about it until next year. When the agents first compared the signed record with the systems, 119 of 412 activities did not match — and a wrong record means an access request that misses a system, a breach notice that cannot say whose data was at the vendor, and a DPIA screening that never triggers.

typical€10Mor 2%of worldwide annual turnover, whichever is higher: the fine ceiling for an Article 30 infringement
demo11weeksfor the demo company's last annual review, with a 58-question survey per activity
demo119of 412activities that did not match their systems when the agents first compared them with the signed record
Where the annual review's working days goestimated
By hand55 days
With the solution5.5 days
  • Sending and chasing the survey for every activity15 → 1.5 d
  • Interviewing department heads about their processing12 → 1.5 d
  • Asking IT which systems hold the data, where, for how long8 → 0.5 d
  • Reading contracts and vendors for recipients and transfers8 → 0.5 d
  • Consolidating the master register and chasing gaps8 → 0.5 d
  • DPO review and signature4 → 1 d

Estimated split of the demo company's 11-week annual review (March 2026), by hand, and of the same work in one quarterly cycle with the solution.

How it works

How the register stays true

Eight agents discover, compare, draft and check each other; owners confirm and the DPO signs.

What comes in
Systems in214 systems, contracts, vendors · read-only, masked
Agents at work
Discovery agentwhat really flows
Contract readerterms, hosting
Then
Reconcilerclaim vs reality
Then
Register agentcited new version
Attestation coordinatorasks the owner
Then
Transfer checkerindependent
Basis and retention checker
A person decides
Owner and DPOconfirm, approve, sign
What comes out
Register in sync
Article 30 record, signed
DPIA, access requests, notice updated
One case, step by step

One newsletter, from a new form field to a signed record

Kestrel & Vane Services B.V. sends a monthly newsletter to 184,300 subscribers. Its record, MKT-007 version 6, was confirmed by its owner on 18 June. In October the systems behind it changed. Here is what happens next, screen by screen, in the working solution.

  1. 01Thursday morning

    Seven things need her, led by the newsletter

    Ana Sousa · Privacy analyst

    Overnight the agents read 214 connected systems and found 4 changes. Ana's home screen counts 361 activities in sync, 23 drifted and 28 unconfirmed, and 7 that need her. At the top: the newsletter now collects date of birth and sends data to a new US vendor, and Owen Pryce has until Mon 19 Oct to confirm.

    Reconciler and transfer checker: “The newsletter record no longer matches its systems.”

  2. 02The register

    The record of processing, with the drift in the cells

    Ana Sousa · Privacy analyst

    Every activity is one row — data subjects, data categories, systems, recipients, transfers, retention, lawful basis — tested against its systems and contracts every week. Where reality differs, a marker sits in the cell itself. On MKT-007: “+ date of birth”, “+ Lumenvale Analytics” and “+ US · no mechanism”, where the register says no transfers outside the EEA.

    “A marker shows what the systems do that the register does not say; click it for the evidence.”

  3. 03Record vs reality

    Five of ten fields drifted — and one more question

    Ana Sousa and the agents

    The activity opens field by field, Article 30(1)(a) to (g) and the lawful basis: what the register says on the left, what the systems show on the right. Since Thu 8 Oct the signup form requires date of birth, now on 2,870 records; a pixel in tag manager container v118 sends hashed email, IP address and device ID to Virginia. Ana asks the agents whether the pixel fires before consent.

    Discovery agent: “Yes. Tag 41 fires on page view with no consent condition, so the pixel runs before the visitor chooses in the cookie banner.”

  4. 04Every value has a source

    The order form, and a transfer with no mechanism

    Contract reader · Transfer checker

    Each citation opens the passage the agent read. The contract reader found Lumenvale's order form CR-7731: hosting in US-East, data processing terms “as set out in Schedule 3”, which is not attached, and clause 7.3, which lets Lumenvale use the data “to improve its services”. The transfer checker, working on its own, found Lumenvale is not on the Data Privacy Framework list and there are no standard contractual clauses.

    Transfer checker: “I will block any version of this record that lists it without one.”

  5. 05Thursday

    Two questions instead of fifty-eight

    Owen Pryce · Process owner

    The attestation coordinator asked Owen two questions, each with its evidence: what is date of birth for, and what is Lumenvale for? He answers a birthday voucher and campaign attribution. The register agent replies that a birthday voucher needs the day and month, not the year, and proposes that the form asks for day and month only and the year is deleted from the 2,870 records. Owen accepts.

    “Your answers go into the record as a proposal, cited to you.”

  6. 06Version 7

    A cited draft — and an independent block

    Register agent · Transfer checker

    The register agent drafts version 7 with 6 changes, each with its source, in a column beside the record. The transfer checker re-checks version 7 on its own: the US transfer still has no mechanism, so it blocks publishing it as live. It names the safe options for the DPO — pause the pixel until a data processing agreement with SCCs Module 2 and a transfer assessment are signed, or remove it.

    Transfer checker: “I re-checked version 7 on my own. The US transfer still has no mechanism, so I block publishing it as live.”

  7. 07The decision

    Approved with conditions, and signed

    Helena Marsh · Group Data Protection Officer

    Transfers and new data categories need the DPO. Helena chooses reason code APR-C, approve with conditions: the Lumenvale pixel stays paused until a data processing agreement with SCCs (Module 2) and transfer assessment TIA-2026-031 are signed; birthday is limited to day and month, with the year deleted from 2,870 records by Fri 23 Oct; and the newsletter privacy notice is updated before the pixel runs again. She types her name and confirms she has read the evidence and the checker's view.

    “Recorded with your name, the time and the evidence on the audit trail.”

  8. 08Published

    Version 7 goes live, and the change ripples on

    Register agent

    Version 7 is published and transfer assessment TIA-2026-031 is opened. Condition 1 goes to Ritu Chandran, the web platforms owner, to pause tag 41. The register agent proposes the follow-on work to its owners: DPIA screening SCR-2026-361 to the privacy officer, Contact.Birthdate and Lumenvale added to the access-request search map, and a redline of section 3 of the newsletter privacy notice. The breach-scope lookup updates itself: 6,020 subscribers and 21,640 visitors.

    Found on Sat 10 Oct, two days after the form changed — not at next March's review.

  9. 09The rest of the week

    Thirty-one drift items, worked in order

    Reconciler

    The drift queue holds 31 items on 23 activities, by severity and due date: interview videos still sent to the US under the 2010 clauses, a wellbeing survey on consent that is now required, a fingerprint template at the Brno plant, a new sub-processor in India. Ana approves low-risk items in bulk within her authority and dismisses a false positive with a reason code; high items go to the DPO.

    Reconciler: “This week I opened 12 items on 10 activities and set aside 5 changes that were not drift, with reasons.”

  10. 10On request

    The Article 30 record, as at any date

    Export assembler

    For Kestrel & Vane Services B.V. as at 15 October, the export assembler freezes each activity at its version on that date, checks every Article 30(1) field from (a) to (g), leaves the 2 new drafts out with a note, attaches an evidence appendix and fingerprints the file. 102 activities are ready for the DPO's signature. Nothing is sent to an authority.

    “Only the DPO signs.”

Who it’s for

Built for everyone who answers for the record.

The same newsletter record, seen by the five people who keep it true — what their year looked like, and what it looks like now.

AS
Ana SousaPrivacy Analyst, Group Privacy Office
Privacy analyst
Before
Runs the annual survey, chases 61 owners and retypes their answers into the master spreadsheet. “I don't want another survey. Show me where the register is wrong and the proof.”
Now
Works a queue of drift items, each with the evidence on both sides; approves low-risk changes and prepares the DPO's decisions.
HM
Helena MarshGroup Data Protection Officer
Data Protection Officer
Before
Signs a record she knows is already stale, with no evidence behind any cell. “If I sign it, every line has to be true today, not last March.”
Now
Approves lawful-basis, transfer, special-category and new-activity changes with a reason code and her signature, with the checker's view in front of her.
OP
Owen PryceHead of CRM and Marketing Operations, Kestrel & Vane Services · 11 activities
Process owner
Before
Gets a 58-question survey per activity once a year and copies last year's answers. “Ask me one clear question, not fifty-eight.”
Now
Answers two questions about what changed, with the evidence shown; his correction becomes a cited proposal nobody retypes.
RC
Ritu ChandranWeb Platforms Owner, Digital · one of 48 IT system owners
IT system owner
Before
Hears about a privacy problem with her signup form or tag manager months after the release. “Tell me which field and which tag, and I'll fix it in the next release.”
Now
Receives the exact field and tag with the DPO's condition attached, and pauses tag 41 the same morning.
PS
Pieter SmitPrivacy Technology Administrator
Privacy technology administrator
Before
Owns the connections the agents read through; one expired token — corporate card expenses — means software bought on cards goes unseen. “If a connection breaks, I want to know before the reconciler goes blind.”
Now
Sees all 13 integrations with their status and last read, reconnects the broken one, and changes rules and clocks as a new settings version the DPO approves.
Built on the engine

8 agents. Each with one job, and hard limits.

Eight agents discover, compare, draft and check each other; owners confirm and the DPO signs.

Discovery agent

Reads connected systems nightly — identity provider sign-ins, warehouse schemas, SaaS admin consoles, web forms and tags, supplier records and card expenses — and reports what personal data really flows where.

  • Reads metadata and at most 50 masked samples per field
  • Never copies personal data out
  • Never edits the register
Contract reader

Reads new and changed contracts, order forms, DPAs and vendor notices: role, sub-processors, hosting, transfer clauses, retention and own-use clauses, each with its page.

  • Cites the page for every term
  • Never judges whether a transfer is lawful
Reconciler

Compares each activity's claims with what its systems and contracts show, weekly and on events; opens drift items with a severity, and records what it set aside and why.

  • Opens items; never closes its own
  • Records a reason for everything it sets aside
Register agent

Drafts new activities and new versions of changed ones, every value cited with a confidence, and proposes the follow-on work when a version is approved.

  • Proposes only; never publishes
  • Asks the owner rather than guess
Transfer checker

Re-derives every transfer on its own: destination, recipient role, adequacy, the Data Privacy Framework list, clause version and transfer assessment.

  • Cannot see the register agent's reasoning
  • Can block publication; cannot approve
Basis and retention checker

Tests the lawful basis — consent records, legitimate interests assessments, employee consent, special-category conditions — and stated against observed retention.

  • Never changes a basis
  • Never deletes data; proposes a deletion job to the IT owner
Attestation coordinator

Runs the quarterly attestation as short conversations: asks each owner only about what changed, with the evidence; reminds and escalates.

  • Never attests for an owner
  • Escalates to the DPO after 10 business days
Export assembler

Builds the Article 30 record for a controller as at a date, with an evidence appendix and a fingerprint.

  • Never sends anything to an authority
  • The DPO signs
Process owner, privacy analyst, DPO

Reason codes, e-signatures. The agents propose; a named person decides.

Ask in plain words

Ask the register, in plain words

Ask about any activity, system, vendor or transfer, or say what to do. The agents answer from the register, its versions, the evidence and the contracts, cite every source, and act only when you say so.

What changed in the newsletter record?

Two things the register does not say. Since Thu 8 Oct the signup form asks for date of birth; 2,870 records hold one. Since Fri 9 Oct a pixel sends hashed email, IP address and device ID to Lumenvale Analytics in Virginia, with no transfer mechanism. Owen Pryce has until Mon 19 Oct.

Which transfers have no mechanism?

Three of 132: Lumenvale Analytics (US, newsletter), Harrowgate Talent (US, still on the 2010 clauses), and Parlwell Labs (India, a new sub-processor from 2 Nov).

Is Lumenvale a controller under 7.3?

Clause 7.3 lets Lumenvale use the data “to improve its services”. For that use Lumenvale decides why and how, so it would be a controller, not our processor (Art. 28(3)). The DPA should remove 7.3 or limit it to de-identified data.

Prepare the Article 30 record for Services B.V.

I have set up the record for Kestrel & Vane Services B.V. as at today: 104 activities, 2 of them new drafts that will be left out with a note, and an evidence appendix. Press “Build the record”; Helena Marsh signs it. Nothing is sent.

Every screen

The working solution, as it ships.

13 screens from the working solution, on its sample data. Pick one to see it large.

TodayWhat needs the privacy analyst: activities in sync, drifted and unconfirmed, what the agents found overnight, and what is coming due.
The register with drift markersOne row per processing activity, with a marker in each cell where the systems no longer do what the record says.
Record vs realityWhat the register says and what the systems show, field by field from Article 30(1)(a) to (g), with the agents' conversation beside it.
The source behind a valueThe contract passage the contract reader cited — clause 7.3 of order form CR-7731 — with who read it, when, and its fingerprint.
The owner answersTwo questions with their evidence instead of a survey; the register agent turns the answer into a cited proposal.
A cited new versionVersion 7 beside version 6 and the evidence, and the transfer checker blocking the US transfer until it has a mechanism.
The DPO approves and signsReason code, conditions, an optional note and a typed-name signature, recorded with the evidence on the audit trail.
The change ripples onDPIA screening, access-request search map, privacy notice redline and breach-scope lookup, each proposed to its owner.
The drift queueEvery drift item with what the systems show, its severity, owner and due date; open, approve low-risk items or dismiss with a reason.
DiscoveryWhere the discovery agent looks, each source's last read, and what it found this week — each with its evidence.
Transfers and vendors132 transfers to third countries by country and mechanism, with the three that have no mechanism first.
The Article 30 recordThe record for one controller as at a date, with an evidence appendix and a fingerprint, ready for the DPO's signature.
Rules and thresholdsWhich changes need the DPO, what counts as drift, confidence, sample limits and when the agents run — each change a new version.
Governance

Built for Article 30: cited, decided, signed and on the record.

Every value citedEvery value in a draft cites its source — a form scan, a tag scan, a contract page, a release note, an owner's answer — and one click opens the passage the agent read, with who read it, when, and a fingerprint.
People decide, by authorityOwners confirm or correct their own activities. The privacy analyst approves low-risk changes; the DPO approves lawful basis, transfers, special-category data, new activities and longer retention, with a reason code and a typed-name signature.
Agents check each otherThe transfer checker re-derives every transfer without seeing the register agent's reasoning, and can block publication until the DPO decides. The reconciler cannot close or dismiss its own drift items.
No one approves their own workNo one approves a version they prepared. Roles decide which buttons a person can press, and the reason is shown on any button they cannot.
Agents read, they do not takeDiscovery reads metadata and at most 50 masked sample values per field, and never copies personal data out. Agents never publish, delete data, pause a tag or send anything outside the company — they propose it to the person who can.
Versioned, logged, reproducibleEvery agent step and every human decision is on the audit trail with the time, the actor, the evidence and a fingerprint, and nothing there can be edited. Register versions are kept, so the record can be rebuilt as at any date.
Configuration

Your privacy practice, as settings

What counts as drift, what needs the DPO and how fast owners answer are settings. The privacy tech admin changes them; each change is a new settings version that takes effect when the DPO approves it.

SettingDefaultChoose from
Changes that need the DPOLawful basis, a new transfer or mechanism, special-category or criminal-offence data, a new activity, retention longer than statedEach on or off
A new recipient inside the EEAOff: the privacy analyst approves itOn (the DPO approves) · off
Retention counts as drift above10%A percentage you type
Propose a change from confidence0.85A confidence you type, from 0 to 1
Samples read per field, masked50A number you type
Discovery, reconciliation and contractsNightly at 02:00 · full reconciliation Sundays at 23:00 · contracts when they arriveTimes and days you type for each
Owner confirms a drift item within5 business days · reminder on day 3 · escalation to the DPO on day 10Days you type for the window, the reminder and the escalation
Attestation cycle and digestsQuarterly · analysts' digest daily at 08:00 · DPO summary Mondays at 08:00A cycle and times you type
Connections

Reads the systems your record is supposed to describe

Identity providersingle sign-on app catalogue and sign-ins, to find software nobody recorded
Cloud data warehouseschemas, tables and column profiles
SaaS admin consolesCRM, HR, marketing automation and support: fields, settings, record ages
Website forms and tag managerform fields, tags and firing rules
Contracts and supplierscontracts, order forms, DPAs and vendor notices; supplier master, purchase orders and corporate card expenses
Your privacy programmethe existing spreadsheet register, DPIA screenings, access-request search maps and the vendor risk register
What it changes

The difference, in numbers.

Every figure is labelled: a target the solution is built to, an estimate, a typical published result, or a proven one.

target
0
transfers without a mechanism left unseen: every contract, tag and vendor notice re-checked on arrival
Found today3 of 132
With agentsseen in days
target
9in 10
activities in sync with their systems; the hero case went from 71% at go-live to 88% in 14 weeks
88%
in sync
target
1.6days
median from a change in a system to a drift item with its evidence, instead of the next annual review
Annual reviewup to 12 months
With agents1.6 days median

“demo” = seen in the working solution, on its sample data · “target” = the design goal, measured in the live solution · “estimated” = our estimate · “typical” = published figures (GDPR Art. 83(4)(a) — fines up to €10 million or 2% of worldwide annual turnover for infringements of Articles 25 to 39; GDPR Art. 30(1) and 30(4) on the content of the record and making it available on request). People, companies, vendors and systems named on this page are fictional — characters and sample data in the working solution.

Questions

What DPOs and privacy teams ask us.

What is Data Mapping and ROPA?

Data Mapping and ROPA is data mapping software for privacy teams that builds the record of processing activities from real systems and contracts and keeps it true. Eight agents read your systems, tags and contracts, test every activity's record against them every week, and draft cited corrections; process owners confirm, and the DPO approves and signs the Article 30 record.

How does it keep the records of processing activities up to date?

The discovery agent reads connected systems every night and contracts when they arrive. The reconciler compares each activity's claims with what the systems and contracts show, weekly and on events, and opens a drift item with the evidence on both sides — or records what it set aside and why. In the demo, the median from a change in a system to a drift item is 1.6 days.

Does it copy personal data out of our systems?

No. The discovery agent reads metadata — fields, tables, tags, settings, record ages — and at most 50 masked sample values per field, and never copies personal data out. The sample limit is a setting.

How does it handle transfers to third countries?

The transfer checker re-derives every transfer on its own — destination, recipient role, adequacy, the Data Privacy Framework list, the clause version and the transfer assessment — whenever a contract, tag or vendor notice arrives. It cannot see the register agent's reasoning, and it can block a version that lists a transfer with no mechanism until the DPO decides.

Do process owners still fill in a survey?

No. The attestation coordinator asks each owner only about what changed, with the evidence the agents saw, in a short conversation; owners with no change confirm in one step. A correction becomes a cited proposal with the owner's reason, so nobody retypes it.

Can we produce the Article 30 record for one entity as at a past date?

Yes. The export assembler builds the record for any controller as at any date from the register's versions, checks every Article 30(1) field, attaches an evidence appendix and fingerprints the file for the DPO to sign. It never sends anything to an authority.

Do people stay in control of the record?

Yes. The agents propose; they never publish a version, close their own drift items, attest for an owner, pause a tag or delete data. Owners confirm, the privacy analyst approves low-risk changes, and the DPO approves lawful-basis, transfer, special-category, new-activity and longer-retention changes with a reason code and a signature. No one approves a version they prepared.

How long does it take to go live?

The Agentic Solution Engine builds and deploys it from your requirements and documents — starting from your existing spreadsheet register, which the register agent reads, de-duplicates and maps to the Article 30 fields — and it goes live once every quality gate has passed. We will walk you through it on your own register first.

See it on
your register.

We'll run Data Mapping and ROPA on your own register and a sample of your systems and contracts.